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Zero Waste Scotland’s Report on scrap flows fundamentally flawed

The Scottish Policy Group (SPG) of the British Metals Recycling Association (BMRA) has called on Zero Waste Scotland (ZWS) to withdraw its report entitled How should Scotland Manage its Scrap Steel? citing serious concerns with its accuracy.


Zero Waste Scotland’s Report on scrap flows fundamentally flawed f

The Group believes that the total apparent lack of engagement with the industry, including the trade association, prior to writing and publishing the report is concerning and has resulted in significant errors in the report.

The data referenced in the report refers to the UK scrap market as a whole and does not differentiate Scotland’s scrap arisings and destinations.

Moreover, the destination of processed Scottish steel scrap is misreported as going to blast furnace steel mills in Turkey.  In reality, the vast majority is shipped to the short-sea market steel mills in continental Europe, predominately Spain. Most of these steel mills operate with electric arc furnaces (EAFs), most with renewable energy grids.

These data errors effectively mean that the report’s cited carbon savings and benefits of locating a steel mill in Scotland are meaningless as they are compared to steel mills in Turkey, not EAFs based in the European Union.

The report states that locating an EAF in Scotland would save transport and energy emissions over current processes. Again, this is incorrect.  Building an EAF in Scotland would result in some 70,000 additional HGV journeys every year to move the stated 820,000 tonnes of processed ferrous scrap in the report. It’s hard to see how this would contribute to achieving Scotland’s net-zero aspirations.

Furthermore, the authors do not set out the type of steel mill to be built, which is a critical oversight as no single steel mill could meet Scotland’s needs, as different mills produce different types of steel product.  

Finally, any new steel mill would have to operate in a global market. There is no mention in the report where the markets for the steel products produced in a Scottish steel mill would be located, and the energy and emissions generated in transporting to those global markets.

ZWS has subsequently stated that, as part of its ongoing work in this area, it will engage with Scottish industry to gain a more detailed understanding of Scottish scrap steel arisings and our export destinations. However, as a Group, we can’t help but wonder if it would not have been better to consult with us before publishing this report? We would urge ZWS to work with the sector before publishing any further reports.

The SPG invited ZWS to a specially arranged meeting to discuss their report and how the Group could assist them in gaining more accurate data. Regrettably, ZWS pulled out of the scheduled meeting due to other meetings, which arose at short notice. We hope to reschedule this meeting early in the new year.

For more information, you can contact Antonia Grey at the BMRA on 01480 455249 or email her at, alternatively, please visit

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Owain Griffiths

Owain Griffiths

Head of Circular Economy at Volvo Cars

Owain joined Volvo Cars in June 2021 to lead Circular Economy in the Global Sustainability Team. The company has committed to being a circular business by 2040 and has financial, recycled content and CO2 based targets for 2025, all of which Owain is working across the company to make happen. Owain previously worked for circular economy consultancy Oakdene Hollins where he advised businesses on evidence led circular economy implementation. 

Turning into a circular business and the importance of vehicle reuse and recycling.

The presentation will cover the work Volvo Cars is doing to achieve 2025 but mainly focus on the transformational work towards 2040 and the business and value chain changes being considered. Attention will be paid to the way vehicles are being dealt with at the end of life and the complexities of closing material and component loops. Opportunities and challenges which Volvo Cars is facing will be presented including engagement with 3rd parties and increasing pressure from stakeholders.

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